“Section 2(24)”

Section References (mined)Section 2Section 2(24)1,946 judgments

The decision most relied on for Section 2(24) is CIT v. AIMIL Ltd. (321 ITR 508), cited in 1,629 judgments on BharatTax.

Leading authorities on Section 2(24)

CIT v. AIMIL Ltd.

321 ITR 508 · 2010 · High Court

1,629

citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT

143 Taxmann.com 178 · 2022 · Supreme Court

1,392

citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.

319 ITR 306 · 2009 · Supreme Court

1,344

citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. Gujarat State Road Transport Corporation

366 ITR 170 · 2014 · High Court

1,158

citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises

298 ITR 141 · 2008 · High Court

706

citing judgments

Employee contributions to provident fund or ESI, even if deposited after the due date specified in the respective welfare statutes, are allowable as a deduction under Section 36(1)(va) if paid before the due date for filing the income-tax return. This judgment aligns the treatment of employee contributions with employer contributions under Section 43B.

(i) CIT v. Merchem Ltd.

378 ITR 443 · 2015 · High Court

631

citing judgments

Belated remittance of employees' contribution to ESI and PF, even if deposited before the due date for filing the return of income under Section 139(1), is not allowed as a deduction. This disallowance falls under Section 36(1)(va) read with Section 2(24)(x), as Section 43B applies only to employer's contributions.

CIT v. Ponni Sugars & Chemicals Ltd.

306 ITR 392 · 2008 · Supreme Court

577

citing judgments

The "Purpose Test" determines whether an incentive or subsidy is a capital or revenue receipt for income tax purposes. If the incentive's purpose is to enable an assessee to set up a new industry or make investments in capital assets, it is a capital receipt and not taxable.

CIT v. Gujarat State Road Transport Corpn

41 Taxmann.com 100 · 2014 · High Court

540

citing judgments

Employees' contributions to provident fund or other welfare funds are deductible under section 36(1)(va) only if paid by the due date specified in the respective welfare fund enactments, and section 43B does not extend this period to the income tax return filing due date under section 139(1).

Judgments citing Section 2(24)

Src Projects Pvt. Ltd., Salem vs. ACIT, Circle-1, Salem

Accordingly, the appeal filed by the assessee is dismissed

ITA 2358/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Nov 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2358/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 V. M/S. Src Projects Pvt. Ltd., The Acit, 4-B, Lakshmipuram, Circle-(1), Gandhi Road, Salem-636 007. Salem. [Pan: Aagcs 3528 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Vasudevan, AdvocateFor Respondent: Mr.Krishna Murthy AT, JCIT

Section 143(1)Section 143(1)(a)Section 154Section 36(1)Section 36(1)(va)

could be held as the income of the appellant/assessee under Section 36(1)(va) read with Section 2(24)(x) of the Act of 1961 or not or whether it is subject to the provisions contained in Section 43-B of the of the Act of 1961, was highly debatable ... consequence of above-stated discussion, the prima facie disallowance of impugned contribution towards ESI and EPF under Section 36(1)(va) read with Section 2(24)(x) of the Act of 1961 made by the Assessing Officer under Section 143(1)(a) by order dated 16.12.2021 is hereby set- aside

Sahyadri Farmers Producer Company Limited, Nashik vs. PCIT, -1, Nashik

In the result, the appeal filed by the assessee is dismissed

ITA 1378/PUN/2025[2020-21]Status: DisposedITAT Pune14 Nov 2025AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1378/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Sahyadri Farmers Producer Vs. Pcit-1, Nashik. Company Limited, Survey No.1102/8, Behind Police Head Quarter, Adgaon, Nashik- 422003. Pan : Aapcs1516D Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amit Bobde Date Of Hearing : 21.08.2025 Date Of Pronouncement : 14.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.03.2025 Passed U/S 263 Of The Act By Ld. Pcit, Nashik-1 [‘Ld. Pcit’] For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Learned Pcit-1, Nashik Erred In Law & On Facts In Assuming Jurisdiction U/S 263 Of The Ita, 1961 On The Analogy That The Order Passed U/S 143(3) Of The Ita, 1961 Dated 19/09/2022 Was Erroneous & Prejudicial To The Interest Of The Revenue. Grounds Relating To Government Grants:

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amit Bobde

Section 143(3)Section 2(24)(xviii)Section 263Section 43(1)

revenue. 3. Learned PCIT erred in law and on facts in treating the government grants as taxable income of appellant as per section 2(24)(xviii) of ITA, 1961 without appreciating that, said grants are reduced from cost of respective assets (for which grants are received) as per explanation ... section 43(1). As such, the such grants are excluded from purview of section 2(24)(xviii). 4. Learned PCIT erred in law and on facts in not appreciating that, various courts have held that, government grants are not revenue in nature and ought to be deducted from cost

Incometax Officer, Ward-1(1), Tiptur vs. Sriudayaravi Credit Co-Op, Tiptur

In the result, appeals of the Revenue are dismissed

ITA 2095/BANG/2024[2018-19]Status: DisposedITAT Bangalore14 Nov 2025AY 2018-19

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

opposed to facts of the case in allowing the entire deduction u/s 80P(2)(a)(i) of the Act. 2. As per section 2(24)(viia)- Profits and Gains of any business of banking(including providing credit facilities) carried on by a co-operative society with its members is "income

Incometax Officer, Ward-1, Tiptur vs. Sri Udayravi Credit Co-Op, Tiptur

ITA 2094/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Nov 2025AY 2017-18

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

Jambo Credit and Thrift Co-Operative Society Limited, Jaipur vs. ITO-6(1), Jaipur

ITA 1109/JPR/2025[2018-19]Status: DisposedITAT Jaipur12 Nov 2025AY 2018-19

Bench: This Appellate Tribunal Feeling Aggrieved By Order Dated 12.06.2024, Passed By Learned Cit(A), Nfac, Delhi, Relating To The Assessment Year 2018-19, As Thereby The Appeal Filed By The Appellant Has Been Dismissed.

For Appellant: Ms. Apksha Kalra, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

specified activities mentioned in section 80P(2) would be eligible for deduction. The word 'income' has been defined under section 2(24)(i) of the Act to include profits and gains of business. This sub-section is an inclusive provision. The Parliament has included specifically business profits' into the definition

Sol Entertainment Private Limited, Mumbai vs. ITO Ward 11(2)(3), Mumbai

In the result, the appeal filed by the assessee stands dismissed

ITA 4924/MUM/2025[2013-14]Status: DisposedITAT Mumbai12 Nov 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 115JSection 139(1)Section 143(3)Section 2(24)(x)Section 250Section 36(1)Section 36(1)(va)Section 43B

deposited within the due dates prescribed under the relevant labour law (EPF/ESIC Acts), failing which the amount shall be deemed income under section 2(24)(x) and disallowed. The Hon'ble Supreme Court further held that the intention of the legislature was to treat employer's and employee's contributions

Ranjit Singh, Panchkula vs. Deputy Director, CPC Department

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Labh Singh, Panchkula vs. Income Tax Officer, Ward No 2, Panchkula

ITA 725/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Bhupinder Singh, Ambala vs. Income Tax Officer, W-1, Ambala

ITA 528/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

For Respondent: Shri Suraj Bhan Nain, Advocate

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Sh. Hakam Singh, Patiala vs. Income Tax Officer, Ward-4, Patiala

ITA 486/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Balbir Singh, Sirsa, Haryana vs. ITO, Ward-1, Sirsa, Haryana

ITA 483/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

For Respondent: Shri Suraj Bhan Nain, Advocate

under the said provision amounts to compensation or not." 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any "other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Bishan Chand, Chandigarh vs. Income Tax Officer, Ward 5 (5), Chandigarh

ITA 458/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

For Respondent: Shri Suraj Bhan Nain, Advocate

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Sat Pal, Chandigarh vs. Income Tax Officer, Ward 5(5), Chandigarh

ITA 243/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Narender Kaur, Kurukshetra, Haryana vs. Income Tax Officer Ward-1, Kurukshetra

ITA 165/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

For Respondent: Shri Suraj Bhan Nain, Advocate

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any "other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Balvinder Singh, Fatehabad vs. ITO Ward-1, Fatehabad

ITA 153/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Gurdeep Singh HUF, Chandigarh vs. ITO, Ward 5(5), Chandigarh

ITA 1153/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any "other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Jarnail Singh, Village Bhagwanpur, Kalka vs. ITO, Ward-2, Panchkula

ITA 1025/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Baljeet Kaur, Nadi Mohalla Ambala City vs. ITO Ward 1, Ambala

ITA 92/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section 2

Arjesh Kumar, Patiala vs. ITO National E-Assessment Centre, Delhi

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Kaka Singh Alias Guljar Singh, Patiala vs. Income Tax Officer, Patiala

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

For Respondent: Shri Suraj Bhan Nain, Advocate

under the said provision amounts to compensation or not. 29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income" referred to in Section 56(2)(viii ... contended that unless a particular receipt is expressly brought within the inclusive definition of “income" under Section 2(24), the same 32 cannot be subjected to tax under Section 56(2)(viii). The Ld. AR pointed out that Section 56(2)(viii) does not have any corresponding mention in Section